--- title: "Financial Industry Regulatory Authority’s Data Strategy Challenged" id: "26365" type: "post" slug: "financial-industry-regulatory-authoritys-data-strategy-challenged" published_at: "2014-12-03T20:55:44+00:00" modified_at: "2026-03-16T13:11:13+00:00" url: "https://associationsnow.com/2014/12/03/financial-industry-regulatory-authoritys-data-strategy-challenged/" markdown_url: "https://associationsnow.com/2014/12/03/financial-industry-regulatory-authoritys-data-strategy-challenged.md" excerpt: "Two associations in the financial industry say that the Financial Industry Regulatory Authority's proposed automated oversight system is overly costly and could prove burdensome for members and extremely invasive for clients." taxonomy_category: - "Advocacy" taxonomy_post_tag: - "AssociationsNow" - "Business" - "FINRA" - "investor protection" - "Professional Association" - "Regulations" - "trade associations" taxonomy_content_format: - "Article" taxonomy_role: - "Association CEO / Executive Director" - "C-Level" - "Executive Team" - "For-Profit CEO / President / Owner / Partner" taxonomy_persona: - "Executive Leadership" --- [Home](https://associationsnow.com/) » [Articles](https://associationsnow.com/format/article/) » Financial Industry Regulatory Authority’s Data Strategy Challenged A high-profile plan to assess potential risks on Wall Street—touted by a key private-sector regulator—is facing criticism from two trade groups this week. According to critics, the Comprehensive Automated Risk Data System (CARDS), a proposed data-collection plan pushed by the Financial Industry Regulatory Authority (FINRA) in recent years, could cost hundreds of millions of dollars to build and could threaten investors’ privacy in the process. It’s led two associations in the sector, the Financial Services Institute (FSI) and the Securities Industry and Financial Markets Association (SIFMA), to argue against the customer-data-collection system. [According to Reuters (opens in a new tab)](http://www.reuters.com/article/2014/12/01/us-finra-brokerage-oversight-idUSKCN0JF3D320141201) , the system would cost $680 million to build, with individual brokerage firms paying anywhere from $390,000 to $8.3 million. The firms would also be on the hook for an annual maintenance and reporting cost of $360 million per year. But in their own analysis of the numbers, both groups suggested that the costs may rise above those initial estimates. In a 35-page comment letter sent to FINRA on Monday, FSI Executive Vice President and General Counsel David Bellaire recommended that the system collect information only on birth year, net worth, and investment-time-horizon data. The institute says that other factors, such as risk tolerance, are already acquired through other means, while other information is difficult to provide in a standard format. [The letter (opens in a new tab)](http://www.financialservices.org/uploadedFiles/FSI_Content/Docs/Advocacy/FSI-Comment_Letter-Regulatory_Notice_14-37.pdf) [PDF] also raises concerns of false-positive results and the extra costs that may come with additional data being added to the system. “In considering the costs of CARDS, FSI member firms wish to note that the costs of complying with regulatory mandates are usually passed down to the customer,” Bellaire wrote. “In developing CARDS it is important to assess the extent of the cost burden to ensure that investors do not experience an increase in the costs of financial services. These costs may exponentially increase when FINRA adds direct business data to CARDS.” Also on Monday, SIFMA Executive Vice President and General Counsel Ira D. Hammerman [sent a letter (opens in a new tab)](http://www.sifma.org/newsroom/2014/sifma_submits_comments_highlighting_significant_concerns_with_the_finra_cards_rule_proposal/) to FINRA. SIFMA’s stance on the CARDS plan goes further than FSI’s, with the association steadfastly opposing the regulatory system on personal-rights and financial grounds. “FINRA has an important investor protection mission and deserves the tools it needs to fully deliver that mission,” [Hammerman wrote (opens in a new tab)](http://www.sifma.org/comment-letters/2014/sifma-submits-comment-letter-to-finra-regarding-finra-s-cards-rule-proposal/) [PDF]. “SIFMA believes that CARDS, as proposed, is not necessary for that mission, would unnecessarily encroach upon the public’s rights of liberty and privacy, would be costly to build, implement and maintain, and at the end of the day would produce more ‘false positives’ due to incomplete information that would drain resources, of both the regulators and the regulated, that could be put to better use to protect investors.” FINRA’s CARDS initiative, which still needs approval from the Securities and Exchange Commission, was first announced in late 2012. (iStock/Thinkstock) [Ernie Smith](https://associationsnow.com/author/ernie-smith/) Ernie Smith is a former senior editor for Associations Now. 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